What is a 'professional degree' and which fields were affected by removing its status?

1. What the Department of Education is defining as a “professional degree”

The RISE negotiated-rulemaking committee produced a working definition that ties “professional degree” to several criteria: doctoral-level status or at least two years of post‑baccalaureate/ six years of postsecondary instruction, preparation for a licensed occupation, and inclusion in specific four‑digit CIP code groupings; the committee then designated a narrow set of core fields that will clearly qualify (e.g., medicine, dentistry, pharmacy, law, veterinary medicine, optometry, podiatry, chiropractic, theology, and clinical psychology) ^[6][7][1].

2. Which fields stakeholders say were affected or excluded

Leading academic and professional groups report that many health and service professions long treated as “professional” would be squeezed out of that higher‑loan category under the draft rule. The Association of Schools and Programs of Public Health warns that MPH and DrPH programs appear excluded ^[3]. The American Nurses Association and other nursing groups say nursing is no longer classified as a professional degree under the department’s proposal ^[4][8]. The Council on Social Work Education flagged social work’s potential exclusion ^[5]. Advocacy and university groups list physician assistants, nurse practitioners/advanced nursing degrees, audiology, occupational therapy and other allied‑health programs among those at risk ^[1][9].

3. Why this matters: loan caps and practical effects

Under OBBBA’s statutory loan architecture, students in “professional degree” programs can borrow more — historically cited as up to $50,000 per year and $200,000 aggregate — while other graduate students face lower caps ^[7]. By narrowing the legal definition and the qualifying CIP‑code list, the rule would reduce the number of programs whose students are eligible for the higher limits, which professional organizations argue could make advanced training less affordable and potentially shrink workforce pipelines in fields like nursing, public health and social work ^[3][5][4].

4. Competing rationales: limiting scope vs. protecting affordability

Supporters of the rule argue a narrow definition prevents an overly broad set of programs from accessing the generous cap and aligns borrowing with programs that typically require extended, licensure‑focused training — emphasizing objective criteria like program length, licensure preparation and CIP codes ^[6][7]. Critics counter that rigid, CIP‑based or length‑based criteria overlook real world licensure structures and costs of many essential professions, and that excluding programs like nursing or physician assistant undermines workforce resilience ^[5][3][4].

5. How consensus was reached and what remains uncertain

Negotiated rulemaking produced a “consensus” draft, but the final regulatory language and any administrative revisions remain subject to further departmental action and public comment; the department initially considered broader interim language and then moved to a multi‑part rubric and a tighter core list during negotiations ^[10][2]. Exact program lists, how CIP codes will be interpreted, and whether some programs will qualify as professional only at the doctoral level are still points of operational detail in current issue papers ^[11][10].

6. Limitations of current reporting and next steps for readers

Available sources document the draft definition, named core fields, and reactions from professional organizations, but do not yet provide final regulatory text or a complete master list of every program added or dropped; therefore specific program‑by‑program eligibility outcomes are not definitive in the reporting cited here ^[1][10]. Stakeholders will submit public comments and the Department may revise its rule, so follow‑up reporting and the department’s formal rule release are necessary to know which degrees ultimately retain or lose “professional” status ^[10][6].